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In discussion with Dame Sara Thornton, UK Independent Anti-Slavery Commissioner

In light of UK Anti-Slavery Day, Sedex welcomed Dame Sara Thornton, the UK Independent Anti-Slavery Commissioner, for an in-depth discussion last week. Dame Sara joined Sedex Head of Responsible Sourcing, Tristan Edmondson, to talk about modern slavery in supply chains, challenges for businesses, and the UK Modern Slavery Act.

Missed the event? Listen on-demand here, or discover the key discussion points below.   

On recent developments and efforts to tackle modern slavery 

  • Events over the past few years have exacerbated the risks of modern slavery, as people around the world become more vulnerable. The coronavirus pandemic and environmental issues are both significant drivers.  
  • Environmental and social issues are deeply linked, and businesses and other stakeholders are beginning to recognise this more. For example, deforestation, climate change and land grabbing leads to people being landless and displaced, making them more vulnerable. They are then more likely to accept sub-standard or exploitative work out of desperation.  
  • With investors paying more attention to social issues and risk management, they are also considering how they can drive change. For example, how can financial services companies and investors use their leverage to support efforts to address modern slavery? 

Read Sedex’s latest report on recognising forced labour risks in supply chains. 

On current challenges, particularly for businesses 

  • Identifying and addressing human rights issues such as modern slavery in the lower tiers of supply chains continues to be a significant challenge. Buying companies have less visibility, no contractual connection, and therefore less leverage with these suppliers.  
  • Businesses fear reputational damage if they uncover forced labour (a form of modern slavery) in their operations or supply chains. We must all accept that modern slavery is an ever-present risk and prepare for the very real possibility that a company might find it. Only then can such exploitation be addressed.  
  • Conflicting priorities in businesses are an obstacle. For example, if a purchasing department only focuses on low prices, which may not reflect the true cost of goods or services, this puts tremendous pressure on suppliers and increases the risk of exploitative working conditions. Leadership commitment is critical, to ensure all departments support the same social and environmental goals. 

“There is no substitute for leadership commitment to upholding human rights and decent working conditions. It is absolutely essential that these issues have senior sponsorship within a company.”

Dame Sara Thornton, UK Independent Anti-Slavery Commissioner

On the UK Modern Slavery Act  

  • The 2015 UK Act was the first of its kind, and it’s right to celebrate this while recognising its limitations. We don’t prosecute enough, so in the eyes of traffickers the risks are low while the rewards remain high. 
  • For example, section 54 of the Act – the requirement that companies produce an annual statement on efforts to address modern slavery – was trailblazing, but there has been no enforcement against companies that don’t comply. We should be pushing on compliance. 
  • The new modern slavery statement registry is helping with monitoring this. People don’t spend hours looking through different websites to scrutinise company statements. These statements are now available in a single place. 

“The requirement to produce a modern slavery statement once a year ensures business leaders have this at the forefront of their minds. Companies are disclosing a lot more because they have to produce a statement, which makes these a really valuable source of information.” 

Tristan Edmondson, Head of Responsible Sourcing at Sedex 
  • The UK Government announced proposed updates to the 2015 Act last year. These haven’t been put into draft legislation yet, but they could form part of an Employment Bill, which is expected in Parliament’s next session. 
  • The USA’s import bans on goods made with forced or child labour are having some impact on business behaviour. The US Government is sending out a clear message that it will not allow goods to be imported when modern slavery has been used in their production.  
  • These bans are already causing ripples internationally. Their influence will spread as other countries adopt similar legislation. Canada and Mexico have signed up to the principles in their recent CUSMA (Canada-United States-Mexico Agreement) trade deal with the USA, and the European Union is looking at introducing similar measures. 
  • Some countries have similar roles to the Independent Anti-Slavery Commissioner (IASC). However, the UK IASC role tends to have a broader remit, which includes promoting best practice within business supply chains, increasing prosecutions, identifying and protecting victims and encouraging academic research in the area. Other countries tend to focus more on victims and prosecutions.

On solutions for businesses to address modern slavery 

  • Companies shouldn’t underestimate this task, nor the agility of the crime groups behind modern slavery. This is intentional, knowing criminal activity, so it is actively covered up.  
  • It’s not really a matter of “whether” forced labour is occurring. The safer assumption for businesses with long international supply chains is that it probably is. Businesses should work to be transparent about their operations to support remediation and prevention. 
  • It is interesting that Sedex have interrogated social audits and highlighted where these are finding the indicators of forced labour. We could make more use of the indicators (defined by the International Labour Organization) to highlight risks.  
  • It’s important to use multiple tools to identify forced labour risks and investigate work sites. For example, support social audits with worker voice tools and risk assessment, and engage non-governmental organisations to support on-the ground investigation. 
  • Worker engagement is critical. This includes capturing their voices through direct feedback, and providing workers with accessible information about their rights.  
  • Consider that absolute statements and generalisations are not helpful. Some industries have a reputation for exploiting workers, but this doesn’t mean that every supplier does. Equally, no country or industry is without the risk – people continue to be trafficked to and exploited in the UK.  

Sedex thanks Dame Sara Thornton for the engaging discussion. Listen to it on-demand here.